Finding 367 (2023-001)

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Requirement
I
Questioned Costs
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Year
2023
Accepted
2023-10-18

AI Summary

  • Core Issue: JTCHS lacks adequate internal controls for federal procurement compliance, specifically not meeting the simplified acquisition threshold.
  • Impacted Requirements: Non-compliance with 2 CFR 200.318(a) regarding documented procurement procedures.
  • Recommended Follow-up: JTCHS should revise its procurement policy to align with federal guidelines, with a target completion by January 31, 2024.

Finding Text

Finding Type: Significant Deficiency Condition: Our audit found that JTCHS did not have adequate internal controls to ensure compliance with the federal procurement requirements. Specifically, JTCHS's procurement policies did not set a simplified acquisition threshold that was compliant with federal requirements. Criteria: Per 2 CFR 200.318(a), General Procurement Standards, “The non-Federal entity must have and use documented procurement procedures consistent with State, local, and tribal laws and regulations for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§200.317 through 200.327. Cause: JTCHS was not aware that its formal written procurement policy was not in compliance with the federal guidelines. Effect: JTCHS was not in compliance with Federal requirements relating to procurement policy. Recommendation: JTCHS should review federal procurement guidelines and revise its procurement policy to be in compliance with the federal procurement guidelines. Responsible Official’s Response: Management will review adopt a procurement policy in accordance with the Uniform Guidance. Planned Implementation Date of Corrective Action Plan: Management has started revising its policy and expects to have a revised procurement policy during fiscal year ending January 31, 2024.

Corrective Action Plan

Recommendation: JTCHS should review federal procurement guidelines and revise its procurement policy to be in compliance with the federal procurement guidelines. Responsible Official’s Response: Management will review adopt a procurement policy in accordance with the Uniform Guidance. Planned Implementation Date of Corrective Action Plan: Management has started revising its policy and expects to have a revised procurement policy during fiscal year ending January 31, 2024.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.958 Block Grants for Community Mental Health Services $693,179
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $488,574
93.959 Block Grants for Prevention and Treatment of Substance Abuse $465,405
93.530 Affordable Care Act - Teaching Health Center Graduate Medical Education Payments Program $278,962
93.917 Hiv Care Formula Grants $269,571
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $242,442
93.914 Hiv Emergency Relief Project Grants $237,968
93.493 None $211,717
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $118,244
93.070 Environmental Public Health and Emergency Response $37,500
10.551 Supplemental Nutrition Assistance Program $30,088
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $10,256
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $7,000